Proco Group – European Privacy Policy

Proco Group – European Privacy Policy

Effective date: 25th May 2018 


Proco Group is a recruitment firm dedicated to filling supply chain roles across the world. Through our global network, we work with current and emerging talent to help individuals develop their careers and with companies to help strengthen their supply chain functions.
Processing of personal data is integral to our business and this policy outlines how we look after your personal information. This includes what you tell us about yourself, information we may gather through our candidate sourcing methods and the choices you make about what marketing you want us to send you. This policy explains how we do this and tells you about your privacy rights and how the law protects you.

This Privacy Policy applies across all three of our brands: Proco Commodities, Proco Associates & Proco Global when operating within the EU.

More information on the Group can be found at, and

How you can contact us 

If you have any questions in relation to our use of your personal information, you should first contact our Data Controllers at:
Data Controller
25 Hosier Lane

Our Privacy Promise

Proco Group is committed to protecting your personal data. To that end, our Privacy Promise is:

  • To keep your data safe
  • To be transparent about how we use your personal data
  • To allow you to manage and review your marketing preferences at any time.

How the law protects you

As well as our privacy promise, you are protected by law.

GDPR ensures that companies only use personal information if we have a proper reason to do so. This includes sharing it outside Proco Group.

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever you process personal data:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for the legitimate interests of the company or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data, which overrides those legitimate interests.

How we collect your personal data

We collect or receive personal data through a number of different channels although this list is not exhaustive:

Contact Us Page: Individuals can apply to us directly through our website by completing the ‘contact us’ enquiry form.
Via telephone or email: Individuals can contact us directly via email or telephone to enquire about possible vacancies that we are handling
Ad responses: Individuals can apply directly for roles that we are recruiting for via adverts posted on various third party websites using a third party provider called Broadbean.
Professional Networks: As an executive search company, we use professional networks such as LinkedIn & Xing as a candidate-sourcing tool.
Recommendations & Referrals: We often receive recommendations and referrals for good candidates in the markets we operate within.

Information about you that may be collected by Proco Group

The following types of information about you may be collected through the various contact channels as described in this Privacy Policy:

Contact & Employment Details

We may collect some or all of the following types of personal data as part of our recruitment methodologies:

  • Name
  • Address
  • Phone Numbers
  • Email Address
  • Job Title
  • Company information
  • CV & information about your career history and aspirations for your next career move
  • Reasons for contacting us
  • Age/date of birth
  • Sex/gender
  • Referee details
  • Immigration status (and whether you have the right to work in the country you are applying for a role)
  • Nationality/Citizenship/place of birth
  • Details about your remuneration, pensions & benefits arrangements
  • Extra information that you choose to tell us
  • Extra information that your referees may tell us

Please note that the above list is not exhaustive.

When you access our websites
You are free to explore the websites without providing any personal information about yourself. When you download our talent trend reports, subscribe to our emails, submit a query via the contact us page or apply for a job on our one of our websites or register for the subscription service, we request that you provide personal information about yourself, and we collect navigational information

Server Log Information 
We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located within the EU.

Use of website server log information for IT security purposes
Our third party hosting provider stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make any attempt to identify you from the information collected via server logs.

Cookies are data files, which are sent from a website to a browser to record information about users for various purposes.

We use cookies to provide links to social network sharing services, and to generate statistical and other information about the use of our website. By continuing to use this website you agree to our use of cookies as described in our Cookie Policy.

The statistical information is gained via Google Analytics tracking software, and is used to help us analyse data about search engine referrers, webpage traffic and to improve the website’s usability.

When a user visits our website, Google Analytics will generate anonymous cookies that convey whether or not you have visited the site before. Your browser discloses if the cookies are already present, and if not, new cookies will be generated.

This allows us to track information such as how many individual unique users we have, and how often they visit the site.

These cookies are anonymous and cannot be used to identify individuals; they are used for statistical purposes and to help improve our website according to its use only.

It is usually possible to prevent your browser accepting cookies by changing your browser’s cookie settings. These settings will typically be found in the ‘options’ or ‘preferences’ menu of your browser.

3rd Party Email & CRM Providers
We use a third party email provider & 3rd party CRM system to store information we collect when you contact us.

Social Media Features
Our websites include social media features, such as the LinkedIn Like button and widgets. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

How your information may be used – Client Data

We work closely with our clients to ensure that they get the best candidates available for the roles they are recruiting.

The data we collect about clients is very limited. It is generally limited to contact details (such as name, telephone number, email address and job & company details).

We use client’s data for many of the recruitment & marketing activities listed below and we will store records of these activities on our database for future reference.

We deem these processes to be necessary for our legitimate interests (as explained in the next section). If you are not happy about this for any reason you have the right to object and can find out how to do this later in this document.

How your information may be used – Candidate Data

The majority of our business activities where we process personal data fall in to ‘Legitimate Interests’ as a legal basis for processing that data. Here is a bit more information to explain what this means in relation to how your data is processed at Proco Group.

A legitimate interest is when we have a business or commercial reason to use your information. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”

We don’t think that any of the following activities that fall in to this category prejudice individuals in any way. We believe that they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis and you can find out how to do so later in this policy.

Here is a list of all the ways that we may use your personal information:

Recruitment Activities

  • Our sole business purpose is recruitment, which means connecting the right candidates with the right jobs. The following list outlines the various ways in which we may use and process your personal data for this purpose.
  • Collecting your data from you and other sources, such as LinkedIn;
  • Storing your personal data on our database, so that we can contact you in relation to recruitment;
  • Providing you with our recruitment services and to facilitate the recruitment process;
  • Assessing data about you against vacancies which we think may be suitable for you;
  • Sending your information to Clients, in order to apply for jobs, to assess your eligibility for jobs within the client company (both current or future roles that may become available);
  • Carrying out our obligations arising from any contracts entered into between us;
  • Carrying out our obligations arising from any contracts entered into between Proco Group and third parties in relation to your recruitment;
  • Facilitating our payroll and invoicing processes;
  • Carrying out customer satisfaction surveys;
  • Complying with our legal obligation in connection with the detection of crime or the collection of taxes or duties; and
  • Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.

Our legal basis for processing: We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests, as we have explained at the beginning of this section.

We think it is reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our recruitment services to you, share that information with prospective employers and assess your skills against the roles we are recruiting for. We need to do these things so that we can function as a recruitment business, and to help you and other candidates get the roles that are right for you.

Marketing Activities 
From time to time, we may use your data to send you information that we think you may find interesting. In particular, to:

  • Enable us to develop and market other products and services;
  • Market our full range of recruitment services;
  • Send you details of reports, promotions, networking and client events, and general information about the functions & sectors which we think might be of interest to you; and
  • Display promotional excerpts from your details on Proco websites (only where we have obtained your express consent to do so)

Our legal basis for processing: We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct marketing to you through digital channels) and we will ask you to opt-in to these services on our marketing preferences portal.

If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time through our marketing preferences portal.

From time to time, even if you have opted-out, your details may be recaptured through public sources in an unconnected marketing campaign. Although we endeavour to avoid this happening, we ask that you opt-out again in these circumstances.

How to change your privacy preferences

You can change your preferences as to how our company uses your information by adjusting the settings to your marketing preferences

Who we share your personal information with

We may share your personal data with our clients as part of our recruitment methodologies.
Other 3rd Parties

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

  • Telephone providers,
  • Email provider,
  • IT service providers,
  • Web developers,
  • Hosting provider,
  • Tax, audit or other authorities
  • Marketing technology platforms and suppliers
  • Your information will be shared with these service providers only where necessary to enable us to run our business.

How long we keep your information for

We retain your information only as long as is necessary for the purpose for which we obtained it and any other permitted linked purposes.

Our retention periods are based on business needs and if your information is no longer needed it is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.

Use for direct marketing: in relation to your information used for marketing purposes, we may retain your information for that purpose for 12 months after, the date we last obtained a consent to market to you, or the date you last responded to a marketing communication from us (other than to opt out of receiving further communications).

Your information may be accessible outside of the EEA subject to suitable safeguards

Our company is a global company. Your personal information may be accessed by our staff from a country outside the European Economic Area (EEA) for any of the purposes set out above. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.

Your Data Protection Rights

Under certain conditions, you may have the right to require us to:

  • Provide you with further detail on how we use your information
  • Provide you with a copy of information that you have provided to us
  • Update any inaccuracies in the information we hold
  • To delete any information we no longer have a lawful ground to use
  • Where processing is based on consent and in relation to any direct marketing to withdraw your consent so that we stop that particular processing
  • To object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
  • Restrict how we use your information whilst a compliant is investigated

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).

How to withdraw your consent for marketing
You can withdraw your consent at any time by amending your marketing preferences.

How to get a copy of your personal information 
You can access your personal information we hold by emailing us or writing to us at the following address and we will endeavour to respond to your request within 30 days.
Data Controller
25 Hosier Lane

Letting us know if your personal information is incorrect
If you believe your personal information that we hold on our database is incorrect, you can notify us either by email or by letter and we will endeavour to update our data within 7 working days. Please state in your communication the data that needs to be amended.
Data Controller
25 Hosier Lane

What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data but please tell us if you think that we should not be using it.
Please write to us to explain why you would like to be removed from our database at the following address:

Data Controller
25 Hosier Lane

We will endeavour to respond to you within 30 days to confirm whether we have been able to comply with your request. 

How to make a complaint if you are unhappy with the way we have used your data

Please let us know if you are unhappy with how we have used your personal information. You can contact us using the email or postal address below:
Data Controller
25 Hosier Lane

You also have the right to complain to your data protection authority.